[Congressional Record Volume 168, Number 200 (Thursday, December 22, 2022)]
[House]
[Pages H9990-H10002]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]




      PRESIDENTIAL TAX FILINGS AND AUDIT TRANSPARENCY ACT OF 2022

  Mr. NEAL. Madam Speaker, pursuant to House Resolution 1529, I call up 
the bill (H.R. 9640) to amend the Internal Revenue Code of 1986 to 
provide for examination and disclosure with respect to Presidential 
income tax returns, and ask for its immediate consideration.
  The Clerk read the title of the bill.
  The SPEAKER pro tempore (Mrs. Luria). Pursuant to House Resolution 
1529, the bill is considered read.
  The text of the bill is as follows:

                                H.R. 9640

       Be it enacted by the Senate and House of Representatives of 
     the United States of America in Congress assembled,

     SECTION 1. SHORT TITLE.

       This Act may be cited as the ``Presidential Tax Filings and 
     Audit Transparency Act of 2022''.

     SEC. 2. EXAMINATION AND DISCLOSURE WITH RESPECT TO 
                   PRESIDENTIAL INCOME TAX RETURNS.

       (a) Audit.--Subchapter A of chapter 78 of the Internal 
     Revenue Code of 1986 is amended by redesignating section 7613 
     as section 7614 and by inserting after section 7612 the 
     following new section:

     ``SEC. 7613. EXAMINATION WITH RESPECT TO PRESIDENTIAL INCOME 
                   TAX RETURNS.

       ``(a) In General.--As rapidly as practicable after the 
     filing of any Presidential income tax return, the Secretary 
     shall conduct an examination to ascertain the correctness of 
     such return and enforce the requirements of this title with 
     respect to the taxable year covered by such return.
       ``(b) Reports.--
       ``(1) Initial report.--Not later than 90 days after the 
     filing of a Presidential income tax return, the Secretary 
     shall disclose and make publicly available an initial report 
     regarding the examination with respect to such return. Such 
     report shall include--
       ``(A) the name of the taxpayer,
       ``(B) an identification of the subparagraph of subsection 
     (c)(1) which describes such return,
       ``(C) the date that such return was filed, and
       ``(D) the date on which the examination with respect to 
     such return commenced (or, if such examination has not 
     commenced as of the date of such report, a detailed 
     description of the reasons that such examination has not 
     commenced).
       ``(2) Periodic reports.--Not later than 180 days after the 
     disclosure of the report described in paragraph (1) with 
     respect to any

[[Page H9991]]

     Presidential income tax return and not later than 180 days 
     after the most recent disclosure of a report described in 
     this paragraph with respect to such return, the Secretary 
     shall disclose and make publicly available a periodic report 
     regarding the examination with respect to such return. Such 
     report shall include--
       ``(A) the information described in subparagraphs (A) 
     through (D) of paragraph (1),
       ``(B) a description of the status of the examination, 
     including a description of the portions of the examination 
     which have been completed, which are in process, and which 
     are anticipated to take place, and
       ``(C) an estimate of the time frame for the completion of 
     the examination, including an identification of factors which 
     could alter such time frame, reasonable estimates of the 
     likelihood of such factors (taking into account the specific 
     facts and circumstances of the examination), and the likely 
     specific effects of such factors on such time frame.

     Notwithstanding the preceding sentence, a periodic report 
     shall not be required under this paragraph with respect to 
     any return after the date on which a final report is 
     disclosed under paragraph (3) with respect to such return.
       ``(3) Final report.--Not later than 90 days after the 
     completion of the examination described in subsection (a) 
     with respect to any Presidential income tax return, the 
     Secretary shall disclose and make publicly available a final 
     report regarding such examination. Such report shall 
     include--
       ``(A) the information described in subparagraphs (A) 
     through (C) of paragraph (1),
       ``(B) the date on which the examination with respect to 
     such return was completed,
       ``(C) a list of the audit materials (as defined in section 
     6103(q)(2)) with respect to such examination, and
       ``(D) a description (including the amount) of each proposed 
     adjustment, adjustment, and controversy with respect to such 
     examination together with a description of how such proposed 
     adjustment or controversy was resolved (or a statement that 
     such proposed adjustment or controversy was not resolved, as 
     the case may be).

     For purposes of this paragraph, an examination shall be 
     treated as complete on the date that the Secretary provides 
     the taxpayer with a notice of deficiency, or any closing 
     document referred to in section 6103(q)(2)(A)(v), with 
     respect to such examination.
       ``(4) Extension of due date report.--If a request is made 
     for an extension of the due date for filing any Presidential 
     income tax return, the Secretary shall, not later than 90 
     days after such request is granted or denied, disclose and 
     make publicly available an extension of due date report with 
     respect to return. Such report shall include--
       ``(A) the information described in subparagraphs (A) and 
     (B) of paragraph (1),
       ``(B) a statement that an extension of the due date for the 
     filing of such return has been requested,
       ``(C) the date that such request was received,
       ``(D) a statement of whether such request has been granted 
     or denied, and
       ``(E) the due date of such return (including any 
     extensions).
       ``(5) Treatment of failure to file.--In the case of a 
     failure to file a Presidential income tax return before the 
     close of the 60-day period beginning with the date prescribed 
     for filing of such return--
       ``(A) the Secretary shall conduct the examination described 
     in subsection (a) with respect to the taxable year covered by 
     the return to which such failure relates,
       ``(B) reports made pursuant to this paragraph shall include 
     a statement that such report is with respect to a return 
     which the taxpayer failed to file, and
       ``(C) this section and section 6103(q) shall otherwise 
     apply to such failure in the same manner as if a return were 
     filed at the close of such period.

     The application of this paragraph with respect to any failure 
     to file a Presidential income tax return shall not prevent 
     the application of this section with respect to such return 
     at such time as such return may be filed.
       ``(6) Public availability.--For purposes of this 
     subsection, a document shall not be treated as having been 
     made publicly available unless made available on the 
     internet.
       ``(c) Presidential Income Tax Return.--For purposes of this 
     section--
       ``(1) In general.--The term `Presidential income tax 
     return' means any relevant income tax return of--
       ``(A) a President,
       ``(B) an individual who is married (within the meaning of 
     section 7703(a)) to a President for the taxable year to which 
     such return relates,
       ``(C) any corporation or partnership which is controlled by 
     any individual described in subparagraph (A) or (B) at any 
     time during the taxable year to which such return relates,
       ``(D) the estate of any person described in (A) or (B) or 
     any estate with respect to which any person described in 
     subparagraph (A), (B), or (C) is an executor, or beneficiary 
     at any time during the taxable year to which such return 
     relates, and
       ``(E) any trust with respect to which any person described 
     in subparagraph (A), (B), (C), or (D) is a grantor, fiduciary 
     or beneficiary, or for which another trust described in this 
     subparagraph is a grantor or beneficiary, at any time during 
     the taxable year to which such return relates.
     Such term shall include any schedule, attachment, or other 
     document filed with such return.
       ``(2) Relevant income tax return.--The term `relevant 
     income tax return' means, with respect to a President, any 
     income tax return if--
       ``(A) any portion of the taxable year to which such return 
     relates is during the period that such President is the 
     President,
       ``(B) the due date for such return (including any 
     extensions) is during such period, or
       ``(C) such return is filed during such period.
       ``(3) Control.--For purposes of paragraph (1)(C)--
       ``(A) In general.--Except as otherwise provided in this 
     paragraph, control shall be determined under the rules of 
     paragraphs (2) and (3) of section 6038(e) (determined without 
     regard to subparagraphs (A) and (B) of such paragraph (2) and 
     without regard to subparagraph (C) of paragraph (3) thereof).
       ``(B) Restriction on family attribution.--
       ``(i) In general.--Except as provided in clause (ii), for 
     purposes of applying subparagraph (A)--

       ``(I) section 318 shall applied without regard to 
     subsection (a)(1)(A)(ii) thereof, and
       ``(II) section 267(c) shall applied by treating the family 
     of an individual as including only such individual's spouse 
     (in lieu of the application of paragraph (4) thereof).

       ``(ii) Exception for recent transfer to family members.--
     For purposes of determining whether any corporation or 
     partnership is controlled by a President under paragraph 
     (1)(C) for any taxable year, clause (i) shall not apply if 
     such corporation or partnership was controlled by such 
     President (after application of clause (i)) at any time 
     during the 4 immediately preceding taxable years.
       ``(d) Application to Amended Returns.--For purposes of this 
     section and section 6103(q), any amendment or supplement to a 
     return of tax shall be treated as a separate return of tax 
     and the determination of when such amendment or supplement is 
     filed, and whether such amendment or supplement is a relevant 
     income tax return, shall be made without regard to the 
     underlying return.''.
       (b) Disclosure.--Section 6103 of such Code is amended by 
     redesignating subsection (q) as subsection (r) and by 
     inserting after subsection (p) the following new subsection:
       ``(q) Disclosure With Respect to Presidential Income Tax 
     Returns.--
       ``(1) In general.--The Secretary shall disclose and make 
     publicly available (within the meaning of section 7613(b))--
       ``(A) each Presidential income tax return (as defined in 
     section 7613(c)),
       ``(B) each report described in section 7613(b), and
       ``(C) any audit materials with respect a return described 
     in subparagraph (A).
       ``(2) Audit materials.--The term `audit materials' means, 
     with respect to any return:
       ``(A) Any of the following which are provided by the 
     Secretary to the taxpayer (or any designee of the taxpayer):
       ``(i) Any written communication which identifies such 
     return as being subject to examination.
       ``(ii) Any written communication which proposes the 
     adjustment of any item on such return, any report by an 
     examiner related to such proposed adjustment, and any 
     supervisory approval of any penalty proposed as part of such 
     adjustment.
       ``(iii) Any memorandum or report of the Internal Revenue 
     Service Independent Office of Appeals with respect to such 
     return, and any denial of any request described in 
     subparagraph (B).
       ``(iv) Any notice of deficiency with respect to such 
     return.
       ``(v) Any closing documents with respect to the examination 
     of such return, including any closing agreement or no change 
     letter.
       ``(B) Any request for referral to the Internal Revenue 
     Service Independent Office of Appeals of any controversy with 
     respect to such return.
       ``(C) Any petition filed with the Tax Court for a 
     redetermination of any deficiency referred to in subparagraph 
     (A)(iv).
       ``(3) Exception for certain identity information.--The 
     information disclosed and made publicly available under 
     paragraph (1) shall not include any identification number of 
     any person (including any social security number), any 
     financial account number, the name of any individual who has 
     not attained age 18 (as of the close of the taxable year to 
     which the return relates), the name of any employee of the 
     Department of the Treasury, or any address (other than the 
     city and State in which such address is located).
       ``(4) Timing of disclosures.--Any information required to 
     be disclosed under paragraph (1) shall be disclosed and made 
     publicly available not later than--
       ``(A) in the case of any income tax return referred to in 
     paragraph (1)(A), 90 days after the date that such return is 
     filed,
       ``(B) in the case of any report referred to in paragraph 
     (1)(B), the deadline specified in section 7613(b) for 
     disclosing such report, and
       ``(C) in the case of the audit materials referred to in 
     paragraph (1)(C), 90 days after the completion of the 
     examination (within the meaning of section 7613(b)(3)) with 
     respect to the return to which such audit materials 
     relate.''.

[[Page H9992]]

       (c) Clerical Amendment.--Subchapter A of chapter 78 of such 
     Code is amended by redesignating the item relating to section 
     7613 as an item relating to section 7614 and by inserting 
     after the item relating to section 7612 the following new 
     item:

``Sec. 7613. Examination with respect to Presidential income tax 
              returns.''.

       (d) Effective Date.--The amendments made by this subsection 
     shall apply to returns, amendments, and supplements filed 
     (and failures to file returns which occur) after the date of 
     the enactment of this Act (and to reports and audit materials 
     with respect to such returns, amendments, supplements, and 
     failures).

  The SPEAKER pro tempore. The bill shall be debatable for 1 hour, 
equally divided and controlled by the chair and ranking minority member 
of the Committee on Ways and Means or their respective designees.
  The gentleman from Massachusetts (Mr. Neal) and the gentleman from 
Texas (Mr. Brady) each will control 30 minutes.
  The Chair recognizes the gentleman from Massachusetts.


                             General Leave

  Mr. NEAL. Madam Speaker, I ask unanimous consent that all Members may 
have 5 legislative days in which to revise and extend their remarks and 
include extraneous material on the bill that is under consideration.
  The SPEAKER pro tempore. Is there objection to the request of the 
gentleman from Massachusetts?
  There was no objection.
  Mr. NEAL. Madam Speaker, I yield myself such time as I may consume.
  Madam Speaker, let me quickly lend my voice to having witnessed a 
superb legislator, Mr. Hoyer, over a long career, and that is exactly 
what the gentleman was and is: a superb legislator.
  Madam Speaker, we are here this morning to affirm that, in America, 
we are a Nation of equal citizens. No person is above the law.
  By doing that, we honor the acknowledgment of congressional oversight 
and responsibility. Congress has a responsibility that dates to Magna 
Carta, and I am prepared to go back to the Battle of Hastings, if 
necessary, in 1066 to make the argument that I have just offered.
  The Ways and Means Committee is entrusted with the oversight of our 
revenue system. The Ways and Means Committee and staff members all 
honor that very profound tradition.
  At the root of it all this morning is our Federal tax system that 
funds the democracy that we all love and cherish. We rely on voluntary 
tax compliance from all Americans and perhaps especially the President, 
who always should model the highest order of compliance.
  On December 13, 49 years ago this month, President Richard Nixon 
asked the Ways and Means Committee chairman through a letter to have 
the Joint Committee on Taxation review his tax returns.
  Let me say something about the Joint Committee on Taxation. Both 
political parties hold the JCT in the highest personal and professional 
esteem.
  This examination established the precedent for congressional 
oversight of Presidential tax compliance.

                              {time}  0945

  Four years ago, our committee began reviewing the mandatory audit of 
Presidential tax returns to see how the IRS was handling the stress of 
a President with complex finances.
  The committee expected to find that mandatory examinations were 
conducted promptly and that more staff had been dedicated to the 
program to meet the more rigorous demands. I would remind all that this 
morning's New York Times--that I read online last evening--highlights 
the fact that Barack Obama and Joe Biden both had their tax forms 
reviewed.
  Instead, after years of stonewalling and litigation that ended at the 
Supreme Court, four Federal court decisions from three courts, our 
committee found that for all practical purposes the mandatory audit 
program was dormant. It wasn't just functioning poorly; it wasn't 
functioning at all. In fact, the IRS did not start its mandatory audits 
until receiving a letter that I sent requesting a President's tax 
forms.
  The IRS has failed to administer its own mandatory audit program 
policies, so the best available recourse is for Congress to fill this 
void with legislation that eliminates the IRS's discretion in the 
matter. That is precisely what we are asking of this institution this 
morning. I can't imagine that anybody, given the controversy of recent 
days, would be opposed to legislation.
  We would require the IRS to publish the President's tax returns, 
audit them in a timely manner, and keep the American public updated on 
the results because the President is not an ordinary taxpayer.
  A reminder, our legislation is about the Presidency, not about a 
President.
  No other American holds this power, or influence, as the leader of 
our executive branch.
  We arrived at this legislation through a deliberate and cautious 
process, as always. These improved guardrails will provide Americans 
the assurance they deserve that our tax code applies evenly and fairly 
to all of us, no matter how powerful.
  The Ways and Means Committee oversight staff pursued the facts about 
mandatory examination procedures with professionalism and diligence. 
They did a great job. I emphasize that there were no leaks by the 
committee leading up to this decision to release our report on the 
mandatory examination process. Imagine that, in Washington for 
something this complex, no leaks.
  We adhered carefully and scrupulously to the law and resisted 
entreaties from the fringe of both political parties as we proceeded 
with great patience and deliberation. No leaks as to how we were to 
move forward.
  This bill, combined with investments in the IRS that we made as part 
of the Inflation Reduction Act, will preserve the integrity of the 
Presidency and our system of tax and ensure that no one in the country 
is above the law.
  Today's legislation, I repeat, is not about a President, it is about 
the Presidency.
  It is not about being punitive or malicious. And for those on the 
other side and those who are witnesses here today, they have worked 
with me for a long time, and they know what I just said is entirely 
accurate.
  The bill we consider today, once again, is about the integrity of the 
Presidency and the integrity of our tax system.
  Madam Speaker, finally, I include in the Record a technical 
explanation of the bill prepared by the staff on the Joint Committee on 
Taxation, which can be found at https://www.jct.gov/publications/2022/
jcx-20-22/
 Mr. NEAL. Madam Speaker, I urge our colleagues to pass this 
legislation, and for the moment, I reserve the balance of my time.
  Mr. BRADY. Madam Speaker, I yield myself such time as I may consume.
  Madam Speaker, I thank Chairman Neal for his leadership of this 
committee and his friendship. You care about the institution; you care 
about this committee. Your word has always been good, and together our 
committees have done good things: banning surprise medical billing, new 
trade agreements with Mexico and Canada, repeated efforts to help 
people save. It has been an honor to serve with you.
  Now, if you will excuse me, I intend to peel the bark off this bill 
in front of us right now.
  Madam Speaker, this bill is a charade. It is a flimsy excuse that for 
years has been used to justify the political targeting of former 
President Trump.
  This week, Democrats in Congress finally accomplished their goal: for 
the first time in history making public the full, actual tax returns of 
a private citizen. This unprecedented action jeopardizes the right of 
every American to be protected from political targeting by Congress.
  We are told President Trump's returns must be released in order for 
the IRS to conduct its Presidential audits. That is absurd. That is 
like going to the doctor and being told your private medical records 
must be released in order to be examined. One has nothing to do with 
the other. And then you would quickly realize, someone just wants to 
release your medical records, and any excuse will do.
  Let me be clear: Republicans' concerns are not whether the President 
should have made his tax returns public as has been tradition, nor 
about the accuracy of his tax returns, that is for the IRS and the 
taxpayer to determine.
  Our concern is that this politically motivated action sets a terrible 
precedent that unleashes a dangerous new

[[Page H9993]]

political weapon reaching far beyond any President, and overturns 
decades of privacy protections for average Americans that have existed 
since the Watergate reforms.
  Our current law was put in place specifically to prevent Presidents 
and Members of Congress from targeting political enemies through their 
tax returns. Unfortunately, the Supreme Court chose not to intervene to 
stop the flimsy and admittedly partisan Democrat efforts to target the 
former President.

  Now, as a result, thanks to this week's actions, longstanding privacy 
protections for all taxpayers have been gutted.
  Going forward, the majority chairman of the House Ways and Means 
Committee and the Senate Financial Committee will have nearly unlimited 
power to target and make public the tax returns of private citizens, 
political enemies, business and labor leaders, or even the Supreme 
Court Justices themselves.
  No party in Congress should hold that power. No individual should 
hold that power to embarrass, harass, or destroy a private citizen 
through disclosure of their private tax returns.
  After nearly half a century, the political enemies list is back in 
Washington, D.C., and it will unleash a cycle of political retribution 
in Congress.
  Many of us in Congress believed the current law was strong enough to 
protect private citizens against this political targeting, but it is no 
longer. That is frightening.
  Republicans will continue to fight to protect American taxpayers from 
this abuse of power that will surely have severe consequences for 
taxpayers and democracy for years to come.
  We have urged our Democrat friends to turn back because making 
private tax information public will be a regrettable stain, both on our 
committee and on Congress. It will make American politics even more 
ugly and divisive. In the long run, we believe every Member of Congress 
will come to regret this.
  Madam Speaker, we strongly oppose this bill today. Not because 
portions of it doesn't have merit, some do, but it has serious flaws, 
of course, because it didn't exist 48 hours ago.
  And had it been brought forward 4 years ago, 3 years ago, 2 years 
ago, as an honest attempt to improve Presidential audits, I am 
convinced we could have found common ground with no need to expose 
private tax returns of anyone. But not now, not this bill, and not this 
way.
  Republicans will not support any measure whose only purpose is to 
provide cover for the political targeting of a private citizen.
  Madam Speaker, I reserve the balance of my time.
  Mr. NEAL. Madam Speaker, I still intend to say kind things about the 
ranking member despite peeling the bark off my legislation.
  Madam Speaker, I yield 1 minute to the gentleman from Michigan (Mr. 
Kildee), a leader on this issue of tax compliance.
  Mr. KILDEE. Madam Speaker, I rise in support of this legislation, the 
Presidential Tax Filings and Audit Transparency Act, legislation that 
ensures that we protect our tax system and ensures that it is fair and 
transparent for all Americans.
  As we have heard, the purpose of the Ways and Means Committee 
investigation and the purpose of this legislation is to ensure that no 
American is above the law, even the President of the United States.
  But shockingly, under the former President, the IRS was not examining 
the President's tax returns as required by their own policy as it had 
for other Presidents before and since. It did not follow its own rules. 
Because of this, there are still glaring questions about whether the 
former President was abiding by our tax laws.
  That is why we needed the information, and that is why we need this 
legislation to require the IRS to examine Presidential returns in a 
timely and complete manner. The American people must have confidence 
that our tax laws apply evenly and justly to everyone.
  Madam Speaker, I thank Chairman Neal for his leadership on this. In 
passing this, we will ensure integrity in our tax system.
  Mr. BRADY. Madam Speaker, I include in the Record an article from 
yesterday's Los Angeles Times confirming the release of tax returns 
does nothing to evaluate the IRS auditing process or to advance any 
legitimate oversight goal.

              [From the Los Angeles Times, Dec. 21, 2022]

  Column: Should Congress Post Trump's Tax Returns Publicly? I Don't 
                                Think So

                         (By Nicholas Goldberg)

       Donald Trump should have released his tax returns when he 
     was running for president, and in not doing so he was 
     deceptive, sleazy and in violation of a long-standing 
     tradition that fosters transparency and honesty. He obviously 
     hoped to hide unfavorable information from the voters.
       Despite that, I don't believe the House Ways and Means 
     Committee should release his tax returns to the public now.
       The committee fought a long battle all the way to the 
     Supreme Court to obtain copies of the returns. It argued that 
     it needed them to evaluate the effectiveness of an IRS 
     program that audits the tax filings of presidents.
       Republicans squawked all the way, saying the Democrats who 
     controlled the committee were being disingenuous, and that 
     no, no, no, they weren't seeking to do a legitimate 
     evaluation--they were just creating a pretext to get ahold of 
     Trump's returns for a humiliating public fishing expedition 
     into what taxes had or hadn't been paid.
       The courts ultimately ruled that the committee could have 
     six years of Trump's federal tax returns. That battle ended 
     last month.
       But on Tuesday, the committee voted to do something that 
     goes well beyond what's necessary to evaluate the IRS' 
     presidential audit program: The committee is now going to 
     release Trump's taxes publicly, posting the full returns 
     (minus certain identifiers like Social Security numbers and 
     bank account numbers) for all to see. And quickly too, in the 
     coming days, before the Democrats lose control of the 
     committee to the Republicans on Jan. 3.
       Why make the returns public? How does that help Congress 
     figure out whether the IRS auditing process is working? How 
     does it further the legitimate oversight goals of the 
     committee?
       Answer: It doesn't. It turns out the Republicans are right. 
     (This may be the first time since the Civil War.) As they 
     correctly noted, this is a politically motivated move to 
     release information that might harm or embarrass the former 
     president.
       In theory, I'm all for embarrassing Trump. (With these two 
     caveats: First, no one can embarrass Trump more than he 
     embarrasses himself, and second, he's entirely shameless so 
     he doesn't really get embarrassed in any normal sense of the 
     word.) The ex-president is a dishonest thug who needs to be 
     called to account for his misbehavior.
       But in this particular case, I think the Democrats are in 
     the wrong. For one thing, releasing the private tax returns 
     probably won't shed much light on anything. The New York 
     Times already received leaked details of more than two 
     decades of Trump's tax filings and published long stories 
     that should've shocked the world. Billionaire pays less in 
     federal taxes in some years than you and I do! Trump paid no 
     federal income taxes at all in 10 out of 15 years!
       Furthermore, the Manhattan district attorney's office has 
     many of Trump's tax returns as well, and prosecutors can 
     pursue cases using the data they uncover.
       But the main reason I object to posting the returns is that 
     I worry--perhaps quaintly, in this day and age--about the 
     continued politicization of governmental processes, and the 
     continued breaking of established norms, in this case making 
     private tax filings public. I know I'll get a thousand emails 
     saying ``the Republicans wouldn't hesitate to do the same to 
     us'' and ``if we're civil and respectful and always play by 
     Marquess of Queensberry rules while our political opponents 
     continue their underhanded tricks, we will always be 
     beaten.''
       There's certainly some truth to that. But there's truth to 
     the flip side too: If nobody plays by the rules, there will 
     soon be no rules to play by. When you're doing something as 
     sensitive and politically explosive as investigating a former 
     president--at a tense time in history when there's talk of 
     civil war and violence is on the rise and bitter political 
     partisanship is smoldering--it makes sense to be careful to 
     respect the established process, be as honest as possible, 
     refrain from unnecessary politicization and not escalate 
     conflict unnecessarily.
       Among other things, posting Trump's taxes seems likely to 
     result in tit-for-tat posting of other people's private tax 
     returns. Will we soon be seeing Hunter Biden's tax returns on 
     the web?
       It'll also give Republicans some basis for saying that, 
     actually, it is Democrats who go low when others go high.
       Unsurprisingly, the committee vote was along party lines. 
     Like so much of what goes on in Washington these days.
       If Congress thinks all presidents or presidential 
     candidates should release their tax returns for public 
     scrutiny--which I believe is a good idea--it should pass a 
     law that mandates that going forward. It should not find 
     circuitous, pretextual ways of going after particular 
     presidents.
       The returns the Ways and Means Committee received 
     apparently showed that Trump often paid little or nothing in 
     federal income taxes between 2015 and 2020 despite reporting 
     millions in earnings, thanks to

[[Page H9994]]

     steep losses elsewhere. That's similar to what the New York 
     Times found in its reporting.
       The unembarrassable Trump once said in a debate when 
     Hillary Clinton accused him of not paying much in federal 
     taxes: ``That makes me smart.''
       Voters need to know more about the sources and scope of 
     presidential candidates' wealth and about potential conflicts 
     of interests.
       But posting Trump's returns at this point and under these 
     circumstances and given the arguments that were made to 
     obtain them, serves politics much more than transparency.

  Mr. BRADY. Madam Speaker, I yield 2 minutes to the gentleman from 
Nebraska (Mr. Smith).
  Mr. SMITH of Nebraska. Madam Speaker, if I might, I thank the 
gentleman for yielding me time. This is probably his last time managing 
a bill, and I thank him for his dedication and diligence as ranking 
member.
  Madam Speaker, I rise today in strong opposition to this bill. I 
think it is one of the most unnecessarily divisive efforts in modern 
history. It has been rushed to the floor with no notice, no hearing, no 
markup, and certainly no opportunity to amend it.
  We are only here as an excuse for Democrats' last-minute rush to 
weaponize private taxpayer information against their opponents. Much of 
the oversight of the Presidential audit program Democrats claim to have 
been seeking could have been conducted without accessing or releasing 
anyone's confidential tax information.
  The Inspector General and the Joint Committee on Taxation could have 
provided an analysis of the start and completion dates of Presidential 
audits without Democrats obtaining or releasing confidential tax 
information.
  The JCT could have provided us an analysis of the efficacy of 
Presidential audits without Democrats obtaining or releasing the 
private tax returns.
  Instead, we are debating a bill which will never be considered in the 
Senate or become law, but solely to paper over the bad decision that 
Democrats made only two nights ago.
  Let's defeat this bill today and start over in January with a 
bipartisan effort to ensure the Presidential audit program is working 
as intended, making sure the President and his family are following the 
law, without rushing to cancel anyone's 6103 protections.
  Mr. NEAL. Madam Speaker, a reminder, 9 out of the last 10 Presidents 
of the United States have publicly offered their tax forms.
  Madam Speaker, I yield 1 minute to the gentleman from Illinois (Mr. 
Danny K. Davis), one of the leaders on this issue.
  Mr. DANNY K. DAVIS of Illinois. Madam Speaker, I thank the chairman 
for putting this bill together.
  We live in a country that is governed by a Constitution, laws, rules, 
and regulations. There are no exemptions, there are no people who could 
be let off because of a position that they hold.
  Tradition has it that we have seen the public is desirous of 
information. They want to know, and I think it is our responsibility to 
make sure that they do.
  Madam Speaker, I strongly support this legislation.
  Mr. BRADY. Madam Speaker, I yield 2 minutes to the gentleman from 
Pennsylvania (Mr. Kelly), the Republican leader of the Select Revenue 
Measures Subcommittee.
  Mr. KELLY of Pennsylvania. Madam Speaker, this phrase keeps coming up 
that no person is above the law. That is true. But, also, no person is 
denied protection under the law.
  Why would we wait 4 years?
  Why would this come up at this time that we have to check the former 
President of the United States' tax returns?
  The answer is because we want to make them public.
  Why do we want to make them public?
  Because we need to have every single citizen understand just who this 
person is and what is in their tax returns with no regard to the 
protections that are already in place that these kinds of things don't 
happen, that they do not become a political weapon.
  Yet, now in the very last days of this session, we have decided that 
this is the most important thing this Congress can do. No other 
President has ever gone through this type of scrutiny.

                              {time}  1000

  We keep saying he is not above the law. He is not above the law. The 
truth of it all is, he is not protected by the law because we are going 
to change the law. We are going to make it a weapon that we can go 
after.
  I will just tell you this: The American people continue to lose 
faith, trust, and confidence in a system that cherry-picks what it 
decides to go after and go after in a way that is detrimental to the 
very form of government that we have.
  To be here today, talking about this, in the last hours of this 
session, has nothing to do with what is good for the American people. 
It is a political hit job. It is sad and, especially in this age, for 
the Ways and Means to be doing this at the end of the year? Horrible.
  Mr. NEAL. Madam Speaker, we were not granted this information until 
the Supreme Court ruled on November 23, and we did not pursue this 
legislation at the last minute. We went through the regular order here, 
indeed, with the gentlewoman from California, who did a great job on 
this. She represented the committee at the Rules Committee session 
yesterday.
  Madam Speaker, I yield 1 minute to the gentlewoman from California 
(Ms. Chu).
  Ms. CHU. Madam Speaker, I rise today in strong support of H.R. 9640, 
the Presidential Tax Filings and Audit Transparency Act of 2022.
  This week, I was shocked to find that the IRS did not comply with its 
own mandate to conduct annual audits of the President's tax returns.
  This mandatory Presidential audit has been in place since 1977. Yet, 
during Trump's 4 years in office, only one mandatory audit was even 
started and none of the audits were completed. The majority of audits 
weren't even started until Trump left office.
  The American people deserve transparency and checks and balances for 
the President, the most powerful person in the world. The bill before 
us would ensure the integrity of this audit in Federal statute and show 
the American public that no one is above the law. I urge my colleagues 
to vote ``yes.''
  Mr. BRADY. Madam Speaker, I include in the Record one page from the 
Democrats' own report showing that, contrary to what we just heard, 
every single year, tax returns at issue are under audit, debunking this 
claim that the IRS hasn't examined the tax return.
       Notably, the IRS sent a letter to the former President 
     notifying him that his tax year 2015 return was selected for 
     examination on April 3, 2019, which is the date the Chairman 
     sent the initial request to the IRS for the former 
     President's return information and related tax returns.
       The designated agents were told by the IRS that two of the 
     entities the Chairman requested were included in the 
     mandatory audit program--DJT Holdings LLC and DJT Holdings 
     Managing Member LLC (DJTH Managing Member). The designated 
     agents found the below information regarding DJT Holdings 
     LLC's date of filing on the transcripts and selection for 
     examination and very little information for DJTH Managing 
     Member.
        Tax Year, Date Return Filed, Date Selected for 
     Examination, Designated by IRS as Mandatory Audit:
       2015, October 10, 2016, July 25, 2019, No.
       2016, October 16, 2017, February 11, 2020, No indication.
       2017, October 8, 2018, March 19, 2021, No.
       2018, October 21, 2019, January 28, 2022, No.
       2019, October 12, 2020, April 5, 2022, No.
       2020, February 21, 2022, None, No.
       During the prior Administration, it was clear that the 
     mandatory audit program was not a priority and was not 
     provided with the resources needed to ensure compliance by 
     the former President. An internal IRS memo stated: ``With 
     over 400 flow-thru returns reported on the Form 1040, it is 
     not possible to obtain the resources available to examine all 
     potential issues.'' The designated agents found that the 
     following issues, among others, warranted examination by the 
     IRS:
       Charitable contributions--whether the 2015 conservation 
     easement deduction of $21 million and other large donations 
     reported on the Schedule A were supported by required 
     substantiation.
       Verification of Net Operating Loss Carryover Schedule--
     whether the amount of net operating loss carryover in 2015 of 
     $105,157,825 and future years was proper.
       Unreimbursed partnership/S corporation expenses--whether 
     the terms of the partnership agreements supported 
     unreimbursed expense deductions totaling $27 million over six 
     years.
       Related party loans--whether loans made to the former 
     President's children are loans or disguised gifts that could 
     trigger gift tax.
       Cost of goods sold deductions by DJT Holdings--whether 
     these deductions of about

[[Page H9995]]

     $126.5 million over five years is appropriate when it is not 
     clear what DJT Holdings is selling from the face of the 
     return.
       LFB Acquisition LLC--whether there is any support for 
     changes in the management fees and general and administrative 
     expenses of LFB Acquisition that were significantly higher in 
     2017 ($1.9 million and $2.8 million, respectively) than 2016 
     ($750,000 and $549,000, respectively) and 2018 ($707,000 and 
     $570,000, respectively).
  Mr. BRADY. Madam Speaker, I yield 5 minutes to the gentleman from 
Missouri (Mr. Smith), the Republican leader of the Budget Committee.
  Mr. SMITH of Missouri. Madam Speaker, we are 12 days, 12 days until 
the Democrat majority does not exist. In 13 days, the Republican 
majority will be in charge.
  Americans are facing the highest spike in prices in 40 years because 
of the one-party Democrat rule in Washington, because of their reckless 
spending.
  The Ways and Means Committee is the committee that affects the 
economy more than any committee in all of Congress. What do the House 
Democrats feel like their last 12 days, their biggest priority is not 
solving issues affecting working-class Americans, but issues targeting 
their main political opponents.
  This legislation is only cover for what they have been campaigning on 
for years, and that is, to get Trump's tax returns.
  Let me tell you, if you don't believe me now, this is called the 
mandatory audit program. It is about auditing all current and former 
Presidents to make sure their tax returns are audited. But the chairman 
of this committee only requested how the mandatory audit program has 
worked for one President, one, and it was a Republican President. His 
name was Donald Trump.
  I asked, on Tuesday, did you request a mandatory audit review process 
on Joe Biden? No.
  Did you request one on Obama? No. Clinton? No. Bush? No. Carter? No. 
But yes, only Trump.
  This is a cover for their political objective, and that is to target 
their political opponents.
  We have heard over and over that no one is above the law; that 
includes everyone in this Chamber.
  On Tuesday, when we sat in this markup, I raised the point, how can 
you release the full tax returns, with all of the private personal 
information of the private citizens, their Social Security number, 
children's Social Security numbers? And I said, we need an amendment to 
redact that information. I was told, we are not going to vote on 
amendments.
  But everyone says that no one is above the law. We were told good 
faith, good faith, would redact the full transcripts, and it would be 
decided by the majority staff.
  Has the minority staff been able to participate in it? No. We don't 
even know what the final documents of the tax returns that are going to 
be released, what they are going to look at.
  This was another example where you had to pass something before you 
know what is in it. That is what Pelosi has done this entire Congress. 
That is exactly what the Ways and Means Democrats did. They have 
charted a new territory for the Ways and Means Committee.
  It is the oldest committee in Congress. It is supposed to be the most 
bipartisan committee in Congress. But they ignited a new political 
tool, that future Congresses will now utilize.
  I have traveled all over the country, 42 States just this year alone, 
and one thing that constantly kept coming up to me is, Congressman, 
look into President Biden's family and how they have been enriched by 
his position.
  In fact, banks have flagged over 150 red flags to Treasury. These are 
suspicious activity reports. Usually, it is because they believe there 
is fraud or money laundering, and this is the Biden family bank 
accounts.
  What about the fact that foreign governments are paying to have their 
principals in the same room as Joe Biden? Or the sale of U.S. natural 
gas to China, of which the Bidens held a 10 percent equity stake, or 
business plans to sell one of the largest sources of cobalt for 
electric vehicles to China, and $11 million made from Hunter Biden's 
``work'' with a Ukraine firm and a Chinese businessman.
  Like I said, over 150 red flags or suspicious activity reports filed 
by banks.
  The SPEAKER pro tempore. The time of the gentleman has expired.
  Members are reminded to refrain from engaging in personalities toward 
the President.
  Mr. NEAL. Madam Speaker, I did indicate, I think, perhaps earlier--
maybe the gentleman was not here--that Mr. Obama and Mr. Biden both 
have had their tax forms audited. The majority staff has offered the 
minority staff, who I have great regard for, the opportunity to 
participate in the redaction process. They chose not to.
  Madam Speaker, I yield 1 minute to the gentleman from Pennsylvania 
(Mr. Evans), another leader on the issue of tax compliance.
  Mr. EVANS. Madam Speaker, I rise today to strongly support this 
legislation.
  I am proud to serve on the Ways and Means Committee which, under the 
chairman's strong leadership, oversees and protects our Nation's tax 
code. Tax fairness is a top priority for me and the Democratic members 
of the Ways and Means Committee.
  The chairman's legislation sends a real message of fairness, 
something we haven't seen before. I encourage all my colleagues to 
support this legislation.
  Mr. BRADY. Madam Speaker, I would note that our professional staff 
was ready to join in redaction; however, we were forced to prepare for 
this floor action and offered to do that together after we were done 
this morning.
  Madam Speaker, I include in the Record a recent legal journal that 
notes that because Ways and Means Democrats did not pursue the 
Presidential audits of any of the other eight Presidents in that 
system, that the committee undermines their own credibility by 
releasing returns outside the context of a comprehensive review, an 
honest review of the Presidential audit program.

               [From Chicago-Kent Law Review, April 1999]

          I.R.C. 6103: Let's Get to the Source of the Problem

                           (By Mark Berggren)


                              INTRODUCTION

       Each year, millions of taxpayers in the United States 
     voluntarily disclose the most intimate details of their 
     private lives to the Internal Revenue Service (``IRS''). A 
     government official can glean, among other things, a 
     taxpayer's name, social security number, marital status, 
     income, and religious and political affiliations from a tax 
     return's attachments and completed schedules. Despite the 
     plethora of private information supplied to the IRS, prior to 
     the enactment of the Tax Reform Act of 1976, Internal Revenue 
     Code (``I.R.C.'') Sec. 6103 stated that a taxpayer's tax 
     return was a ``public record'' and as such was ``open to 
     inspection only upon order of the President and under rules 
     and regulations prescribed by the Secretary or his delegate 
     and approved by the President.''
       The lack of protection afforded to returns and return 
     information resulted in the widespread misuse of what 
     taxpayers believed was confidential information. These abuses 
     took the forms of the unauthorized use of tax information for 
     political purposes by presidential administrations and the 
     authorized use of tax information by governmental agencies 
     other than the IRS. However, it was not until the Watergate 
     scandal that these governmental abuses were thrust into the 
     public limelight. The Watergate investigation led to 
     allegations that President Nixon had used return information 
     for unauthorized purposes and sought to use IRS audits and 
     investigations for political purposes.
       In response to these misuses of tax information and their 
     potential effect on the voluntary assessment system, Congress 
     amended I.R.C. Sec. 6103. The amended version of Sec. 6103 
     states that return and return information (``tax 
     information'') shall be confidential and shall not be 
     disclosed except in thirteen specific circumstances. 
     Violations of this prohibition may result in criminal 
     sanctions under Sec. 7213 and civil sanctions under 
     Sec. 7431.
       These necessary amendments, however, have not silenced the 
     controversy surrounding Sec. 6103. Section 6103's thirteen 
     exceptions do not contain an exception for tax information 
     that is part of a public record. This omission forced several 
     of the Federal Courts of Appeal to consider the question of 
     whether an authorized disclosure of tax information that 
     subsequently becomes part of a public record loses its 
     Sec. 6103 protection. In order to resolve this question, the 
     Federal Courts of Appeal have adopted different approaches to 
     the problem. The Sixth and Ninth Circuits look to see if the 
     disclosed tax information has lost its confidentiality. Based 
     on this analysis, these circuits reason that tax information 
     that is part of a public record is no longer confidential 
     and, thus, loses its Sec. 6103 protection. In contrast to 
     this approach, the Fourth and Tenth Circuits look at the 
     literal language of Sec. 6103. Because Sec. 6103 has no 
     public records exception to its nondisclosure norm, these 
     circuits conclude that tax information in a public record is 
     still protected by Sec. 6103 and any subsequent disclosures 
     of that information violate Sec. 6103. Not to be outdone, the 
     Seventh and Fifth

[[Page H9996]]

     Circuits have also considered the issue. These circuits focus 
     on the source of the information disclosed. If the disclosure 
     is taken directly from a public record, the disclosure does 
     not contain tax information as statutorily defined and 
     Sec. 6103 is not violated. However, if the disclosure comes 
     directly from tax information, then Sec. 6103 is violated 
     regardless of whether the disclosure is also part of a public 
     record.
       The resolution of this issue has far-reaching implications 
     if one considers the answer's potential effect on taxpayer 
     compliance. If courts create judicial exceptions to 
     Sec. 6103, taxpayers may not comply with tax laws because 
     their tax information will not be protected from governmental 
     abuse. On the other hand, if the IRS is prevented from 
     publicizing any tax information taken from any source, it may 
     be unable to deter noncompliance. The legislative history of 
     Sec. 6103 indicates that Congress was aware of these concerns 
     and sought to balance them in Sec. 6103 in order to maximize 
     taxpayer compliance. However, both Sec. 6103 and its 
     legislative history are silent as to whether tax information 
     that is part of a public record loses its Sec. 6103 
     protection. Thus, a uniform interpretation of Sec. 6103 is 
     needed not simply for uniformity's sake, but for the effect 
     on taxpayer compliance.
       This note explores each circuit's approach to the public 
     records problem and its possible effect on taxpayer 
     compliance. Part I provides the history of Sec. 6103 with an 
     emphasis on the legislative purpose behind the 1976 
     amendments to Sec. 6103. Part II outlines the split in the 
     circuits according to the three approaches the circuits have 
     taken: the confidentiality approach, the disclosure approach, 
     and the source approach. Because the Fifth Circuit's recent 
     decision is the most comprehensive analysis of the public 
     record disclosure dilemma to date, this note discusses its 
     opinion in detail. In Part III, the note critiques each 
     approach in light of the legislative and political history 
     behind Sec. 6103. It concludes that the ``source'' approach 
     of the Seventh and Fifth Circuits is the best approach 
     because it effectuates the purpose behind Sec. 6103 without 
     imposing a judicially created exception on Sec. 6103.

  Mr. BRADY. Madam Speaker, I yield 3 minutes to the gentleman from 
Kansas (Mr. Estes).
  MR. ESTES. Madam Speaker, I thank my friend from Texas for yielding.
  Madam Speaker, what a shameful way for the majority to end their 
reckless tenure in House leadership.
  Today, we are debating and voting on rushed bills that will cost 
Americans trillions of dollars, expand the Federal government, and 
eviscerate personal privacy.
  The timing of this atrocious bill is an assault on the institution 
and further undermines the public trust in the United States House of 
Representatives and Federal agencies.
  Let us be clear: This bill has one purpose, to help the majority 
party justify their prejudiced release of personal and private data of 
the former President, his wife, and his 16-year-old son.
  The supporters of this bill claim that releasing personal tax returns 
is needed to prove the Presidential mandatory audit process works. It 
does not.
  Congress should oversee the Presidential mandatory audit process to 
ensure it does work correctly; but this invasion of privacy does not do 
that.
  Another point, the Presidential mandatory audit process is completely 
separate from the voluntary release of tax returns done by seven of the 
last nine Presidents.
  Democrats have supercharged the IRS weapon to not only go after 
political enemies, but their spouses and minor children, too. Minor 
children aren't even exempt from the Democrats' desire to take down 
their opponents.
  Regardless of one's political preferences or attitudes toward a 
former President, every American should be vehemently opposed to this 
un-American attack on privacy, and I urge my colleagues to vote ``no.''
  Mr. NEAL. Madam Speaker, the former Commissioner of the IRS has 
indicated in the last 24 hours that he had no idea as to how the actual 
audit of a President's forms played out. That is not from me; that is 
from the public record.
  Madam Speaker, I yield 1\1/2\ minutes to the gentleman from 
California (Mr. Panetta) who has had a profound interest in this issue.
  Mr. PANETTA. Madam Speaker, let me start off by expressing my 
gratitude for Chairman Neal, for his seriousness, his sincerity, and 
his solemnity in his leadership in the Ways and Means Committee and in 
the way he conducted this request and release of the former President's 
tax returns and the writing of this legislation before us.
  Because of him, throughout this odyssey, the members of the Ways and 
Means Committee always knew and felt the gravity, the implications of 
what it meant to release an individual's tax returns.
  In fact, prior to this weekend, which was prior to my review of the 
former President's tax returns, I admit, I had no intent on voting to 
release them. However, that changed. That changed once we were able to 
obtain the returns, based on a valid legislative purpose and confirmed 
by the Supreme Court, go through the returns, and see the complete 
failure of the IRS when it comes to their Presidential audit program, a 
program that is absolutely necessary to ensure that the world's most 
important public servant is abiding by the law, paying his or her taxes 
like you and me, and free from any conflicts of interest.
  But clearly, the IRS doesn't appreciate, nor does it prioritize the 
importance of this program, especially during the last administration 
because, as applied to the former President, not one audit was 
completed, despite what the President said to the American public.
  That is why I support this legislation, so that any President's 
personal and business tax returns are audited and made public, and we 
are aware of those returns that are audited.
  I am proud to say that under the leadership and seriousness of 
Chairman Neal, now Congress needs to do its job and pass H.R. 9640.
  Mr. BRADY. Madam Speaker, I yield myself 20 seconds to note that 
every year of President Trump's tax returns are under audit.
  Madam Speaker, I include in the Record an article explaining the 
purpose of the taxpayer privacy law the Democrats have dismantled this 
week, exposing all Americans to political attack via tax information.

                    [From the Lawfare, Dec. 2, 2022]

   House Democrats Can Release Trump's Tax Returns. But Should They?

                          (By Daniel J. Hemel)

       Now that a House committee has obtained access to six years 
     of former President Trump's tax returns, congressional 
     Democrats face an easy question and a harder one.
       The easy question is whether, as a matter of law, the House 
     Ways and Means Committee--which gained access to the former 
     president's tax filings after the Supreme Court dismissed 
     Trump's last-ditch bid to block the Internal Revenue Service 
     from handing over the documents--can make Trump's returns 
     public before Republicans take control of the chamber on Jan. 
     3. The answer to that question is straightforwardly yes.
       The harder question is whether, as a normative matter, the 
     committee ought to make Trump's returns public in the waning 
     weeks of the Democratic majority.
       On the one hand, Trump's tax filings should have seen the 
     light of day long ago. Trump should have released his returns 
     voluntarily--as every elected president since Richard Nixon 
     has. The Trump administration should have allowed the IRS to 
     hand the president's tax returns over to the House Ways and 
     Means Committee when that panel's chair, Rep. Richard Neal 
     (D-Mass.), requested those documents in April 2019. And the 
     federal judiciary shouldn't have allowed Trump to stall the 
     release of his returns for three and a half years through 
     litigation.
       On the other hand, the Ways and Means Committee has 
     maintained throughout the litigation over Trump's tax 
     returns--which culminated with last week's Supreme Court 
     decision--that it is seeking the documents as part of its 
     plan to review the IRS's presidential audit program. (The 
     presidential audit program is the procedure--mentioned in an 
     IRS manual but not codified in any statute or regulation--by 
     which the IRS examines individual tax returns filed by the 
     president and vice president each year.) Any review of the 
     presidential audit program that starts now and ends when the 
     GOP takes control of the House in January would be slapdash 
     and superficial. If Democrats on the House Ways and Means 
     Committee rushed to release Trump's returns in the lameduck 
     session--without conducting the comprehensive review of the 
     presidential audit program that they promised--it would look 
     like their stated motive for seeking the documents was 
     indeed, as Trump has alleged, pretextual.
       Fortunately, the Senate Finance Committee--which will 
     remain under Democratic leadership in the next Congress--has 
     both the resources and the apparent inclination to conduct 
     the comprehensive review of the presidential audit program 
     that House Democrats initially set out to undertake. So even 
     if the House Ways and Means Committee doesn't release Trump's 
     tax returns this month, the likely consequence is not that 
     Trump's returns will remain under wraps forever. The Senate 
     Finance Committee will be able to obtain the returns itself, 
     and that committee then can release return information that 
     is relevant to its review of the presidential audit program.

[[Page H9997]]

       Full disclosure: I've been advocating for the release of 
     President Trump's tax information since April 2017, when I 
     suggested in a Washington Post op-ed and a Yale Law Journal 
     Forum article that New York could enact a law requiring the 
     release of Trump's state tax filings. I've advised state 
     lawmakers in New York on strategies to make Trump's tax 
     returns public. I've criticized House Ways and Means Chairman 
     Neal for acting too slowly to obtain Trump's returns. So I'm 
     no apologist for Trump's tax secrecy.
       Still, it's important that Democrats on the House Ways and 
     Means Committee remain true to their word. Chairman Neal said 
     his committee needed Trump's tax returns to evaluate the 
     extent to which the IRS audits and enforces federal tax laws 
     against the president. To turn around now and release Trump's 
     returns--outside the context of a thorough evaluation of the 
     IRS's presidential audit program--would make the stated 
     rationale look much like a head fake. That would seem 
     especially gratuitous given that the Senate Finance Committee 
     stands ready, willing, and able to carry out its own review 
     of the presidential audit program.


The Easy Question: Can House Democrats Make Trump's Tax Returns Public?

       The law is clear that the House Ways and Means Committee 
     can now make Trump's tax returns public if a majority of the 
     committee members vote to do so.
       The relevant statute, Section 6103(f) of the Internal 
     Revenue Code, instructs the IRS to release otherwise-
     confidential tax returns or return information to three 
     congressional tax committees--the Senate Finance Committee, 
     the House Ways and Means Committee, and the Joint Committee 
     on Taxation--upon written request from the chair of any of 
     those panels. The statute also instructs the IRS to release 
     returns or return information to other congressional 
     committees under a narrower set of circumstances.
       The key language regarding the receiving committee's 
     confidentiality obligations lies in Section 6103(f)(4). That 
     paragraph says that any return or return information obtained 
     by the Senate Finance Committee, House Ways and Means 
     Committee, or Joint Committee on Taxation ``may be submitted 
     by the committee to the Senate or the House of 
     Representatives, or to both.'' It goes on to say that any 
     return or return information obtained by another committee 
     ``may be submitted by the committee to the Senate or the 
     House of Representatives, or to both, except that any return 
     or return information which can be associated with, or 
     otherwise identify, directly or indirectly, a particular 
     taxpayer, shall be furnished to the Senate or the House of 
     Representatives only when sitting in closed executive session 
     unless such taxpayer otherwise consents in writing to such 
     disclosure'' (emphasis added).
       Some textualist judges and justices are fond of the Latin 
     phrase ``expressio unius est exclusio alterius'': the 
     expression of one thing is the exclusion of the other. But 
     one doesn't need to be a textualist--or a classicist--to 
     recognize the importance of the contrast between the two 
     submission provisions. Absent the taxpayer's consent, other 
     committees can submit returns to the full Senate or House 
     ``only when sitting in closed executive session.'' The Senate 
     Finance Committee, House Ways and Means Committee, and Joint 
     Committee on Taxation can submit returns to the full Senate 
     or House without condition.
       Judge Trevor McFadden of the U.S. District Court for the 
     District of Columbia reached the same conclusion in his 
     December 2021 decision rejecting Trump's bid to block the IRS 
     from releasing his returns. ``It might not be right or wise 
     to publish the returns,'' McFadden wrote, but the House Ways 
     and Means Committee has the ``right to do so.'' And if the 
     House Ways and Means Committee exercises that right with 
     respect to Trump's returns, its action wouldn't be 
     unprecedented: In 2014, the House Ways and Means Committee 
     published return information regarding 51 taxpayers as part 
     of its investigation into allegations that the IRS had 
     discriminated against conservative nonprofit organizations 
     seeking tax exempt status.
       In the definitive scholarly treatment of Section 6103(f), 
     longtime University of Virginia law professor George Yin, who 
     served as chief of staff of the Joint Committee on Taxation 
     from 2003 to 2005, concludes that the choice to allow the 
     three tax committees to publish private tax information was a 
     ``conscious decision'' by Congress. Prior to 1976, Yin 
     explains, the president--along with the three congressional 
     tax committees--had statutory authority to make return 
     information public. A 1976 amendment eliminated the 
     president's authority to publicize return information but 
     preserved the power of the three tax committees. ``Congress 
     no doubt felt compelled in 1976 to preserve some outlet for 
     Congressional disclosures to the public,'' Yin writes, and it 
     ``was natural to give this authority to the tax committees.''
       On top of all this, the Speech and Debate Clause immunizes 
     lawmakers from liability for statements they make in 
     committee and on the House or Senate floor. So even if it 
     weren't for Section 6103(f)(4), a Ways and Means Committee 
     member could--without legal consequence--read Trump's tax 
     returns aloud, line by line, with the C-SPAN cameras rolling. 
     But House Democrats don't need to rely on constitutional 
     super-immunity here: The relevant statutory provisions 
     clearly empower the Ways and Means Committee to enter Trump's 
     tax returns into the public domain.


  The Hard Question: Should House Democrats Make Trump's Tax Returns 
                                Public?

       Before delving into the normative question of whether the 
     House Ways and Means Committee ought to publish Trump's tax 
     returns, let's clear three points out of the way.
       First, presidents ought to release their tax returns. 
     Disclosure of presidential tax returns helps to dispel the 
     pernicious notion that taxpaying is only for the ``little 
     people.'' Disclosure also helps voters and lawmakers evaluate 
     presidential conflicts of interest (for example, by revealing 
     whether presidents would benefit personally from their 
     administrations' tax proposals). Finally, disclosure serves 
     as a check on improper presidential influence over the IRS. 
     By virtue of their position at the apex of the executive 
     branch, presidents are the nation's tax enforcers-in-chief, 
     but they are also taxpayers against whom the federal tax laws 
     may be enforced. Disclosure helps to reduce the risk that 
     presidents will exploit their dual roles to their own 
     pecuniary advantage.
       Second, the Trump administration should have allowed the 
     IRS to release Trump's tax returns to the House Ways and 
     Means Committee when Chairman Neal requested those returns in 
     April 2019. Section 6103(f)'s instructions are clear: ``Upon 
     written request from the chairman of the Committee on Ways 
     and Means'' or the chair of the other congressional tax 
     panels, the treasury secretary (or the IRS commissioner as 
     the secretary's delegee) ``shall furnish such committee with 
     any return or return information specified in such request'' 
     (emphasis added). The statute makes no exception for cases in 
     which disclosure might embarrass the president. And while 
     case law suggests that the executive branch may reject an 
     information request from Congress if the request does not 
     further a ``legitimate task of Congress,'' Neal's April 2019 
     request manifestly stated a legitimate basis: so that his 
     committee could conduct oversight of the IRS's presidential 
     audit program and, if needed, consider legislative reforms 
     related to presidential audits.
       Third, the litigation over Neal's April 2019 request 
     shouldn't have dragged on for as long as it did. It was 
     nearly three and a half years ago--in July 2019--when the 
     House Ways and Means Committee first asked a D.C. federal 
     district court to order the IRS to hand over Trump's returns. 
     The lengthy delay in resolving that litigation meant that 
     Trump could effectively evade congressional oversight of the 
     presidential audit program for the duration of his term. 
     Fault for the delay lies at the feet of multiple people-and 
     Neal himself bears some culpability for waiting until April 
     2019 to submit his request and until July 2019 to file his 
     lawsuit rather than seeking the returns immediately after 
     Democrats took control of the House in January of that year. 
     However one allocates blame, though, it shouldn't take three 
     and a half years for the federal courts to confirm that the 
     word ``shall'' in Section 6103(f) really means ``shall.''
       But here we are in December 2022, and over the course of 
     the three-and-a-half-year fight over Trump's returns, Neal 
     and other members of the House Ways and Means Committee made 
     several statements that constrain their options now. In the 
     initial April 2019 letter requesting Trump's returns, Neal 
     said his committee needed the documents ``to determine the 
     scope'' of the IRS's audit of the president ``and whether it 
     includes a review of underlying business activities required 
     to be reported on the individual income tax return.'' As 
     recently as last month, the Ways and Means Committee told the 
     Supreme Court that its document request ``is well-tailored to 
     illuminating how the IRS conducted any audits of Mr. Trump 
     while he was President and whether reforms are needed to 
     enhance the IRS's ability to audit Presidents in the 
     future.'' Throughout the litigation, Neal and the House Ways 
     and Means Committee adamantly denied that ``the request is 
     driven by exposure solely for the sake of exposure'' (as 
     Trump had argued). In a June 2021 letter to Treasury 
     Secretary Janet Yellen and IRS Commissioner Charles Rettig, 
     Neal put it succinctly: ``There have been claims''--including 
     from Trump himself--``that the true and sole purpose of the 
     Committee's inquiry here is to expose President Trump's tax 
     returns. These claims are wrong.''
       Plainly, the House Ways and Means Committee is not going to 
     be able to carry out a thorough evaluation of the IRS 's 
     presidential audit program in the four and a half weeks 
     between now and the GOP takeover. The committee's document 
     request is extensive: It has asked for returns filed by Trump 
     and seven of his business entities from tax years 2015 
     through 2020, a status report for each audit, and 
     administrative files such as examiner workpapers associated 
     with each of the Trump returns. With competing demands for 
     the attention of committee members and staffers (including a 
     Dec. 16 deadline to avert a government shutdown), reviewing 
     those documents may consume the better part of the next four 
     and a half weeks. But even after the committee reviews all 
     those documents, it will still need more information before 
     it can complete the comprehensive assessment of the 
     presidential audit program that it has promised.
       For example, the committee will need to know how the IRS's 
     handling of items on Trump's tax returns compares to the 
     service's treatment of similar items on returns filed by 
     other high-net-worth business owners who weren't president of 
     the United

[[Page H9998]]

     States. If the IRS allowed Trump to claim an inflated 
     charitable contribution deduction for a conservation easement 
     at his golf course in Westchester County, New York, is that 
     because examiners gave special treatment to Trump, or is it 
     because the service generally lacks the resources to 
     challenge conservation easement appraisals? The committee 
     also will likely need to hear testimony from IRS examiners 
     involved in the presidential audit program. Did they 
     personally experience improper political influence? And the 
     committee will need to compare the audits of Trump's returns 
     to audits of other presidents and vice presidents. For 
     example, when Joe Biden became president, did the IRS go back 
     and review Biden's aggressive use of a self-employment tax 
     loophole to save hundreds of thousands of dollars on his and 
     his spouse Jill's 2017 and 2018 returns? While Biden--unlike 
     Trump--released his returns voluntarily, we don't know what 
     happened to those filings after they entered the IRS audit 
     vortex.
       To be sure, the House Ways and Means Committee could begin 
     its review of the presidential audit program now and then 
     release everything it has when the clock strikes noon on Jan. 
     3, like a test-taking student who drops her pencil mid-
     sentence when the proctor says ``time's up.'' Trump's tax 
     returns and additional information collected by the committee 
     would then enter the public domain, allowing journalists and 
     others to probe further. If Neal and the House Ways and Means 
     Committee had said all along that their purpose was to 
     vindicate the principle of presidential tax transparency 
     using the powers at their disposal under Section 6103(f), 
     perhaps that course of action would be justified. Indeed, 
     releasing Trump's tax returns for the sake of releasing 
     Trump's tax returns might not be such a bad thing--given all 
     the arguments for presidential tax transparency outlined 
     above.
       Yet Neal and the House Ways and Means Committee insisted 
     all along that their motive was not exposure for the sake of 
     exposure. That was a strategically wise thing to say for 
     litigation purposes, but the statement circumscribes what 
     they can (or, at least, should) do next. Neal and the House 
     Ways and Means Committee would undermine their own 
     credibility--and could be seen as hoodwinking the courts and 
     the public--if they proceeded to release the returns outside 
     the context of a comprehensive review of the presidential 
     audit program.


                       Can the Senate Take Over?

       Enter stage left: the Senate Finance Committee. While the 
     Republicans who take control of the House Ways and Means 
     Committee in January are exceedingly unlikely to continue the 
     Democrats' inquiry, the Senate Finance Committee under the 
     leadership of Chairman Ron Wyden (D-Ore.) is quite capable of 
     conducting the comprehensive review of the presidential audit 
     program that House Democrats won't be able to complete. Wyden 
     will have to send his own written request to the IRS for 
     Trump's returns, but this shouldn't be much more than a 
     formality: Wyden could send the request this morning, and the 
     IRS could send the documents back this afternoon. There is no 
     requirement that Wyden or the IRS even inform Trump of the 
     request before the IRS fulfills it. By the time Trump could 
     file a lawsuit to stop the IRS from complying, Wyden already 
     would have the documents in hand. In any event, a lawsuit by 
     Trump to stop the IRS from fulfilling Wyden's request would 
     be frivolous given the D.C. Circuit's decision resolving the 
     issue in the House litigation--and almost certainly would be 
     dismissed much more quickly than Trump's earlier bid to block 
     the House.
       Section 6103(f)(4) also allows Neal, as chair of the House 
     Ways and Means Committee, to appoint agents to examine the 
     returns that he has obtained through his request. In theory, 
     Neal could appoint Senate Finance Committee staffers--or 
     Chairman Wyden himself--as the House committee's agents. But 
     Neal's GOP successor as House Ways and Means chair could 
     revoke that appointment, ending the Senate's inquiry in 
     midstream. Thus, the better course of action is clearly for 
     Wyden to issue his own written request for the returns on the 
     Senate Finance Committee's behalf.
       In sum, even as the window closes for the House Ways and 
     Means Committee to conduct a comprehensive review of the 
     presidential audit program, Congress still can comb through 
     Trump's tax returns and determine whether the IRS fairly and 
     fully audited the former president. It would be in a 
     different chamber of Congress--the Senate, not the House--but 
     Trump would nonetheless be subject to legislative branch 
     scrutiny.
       Hopefully, House Democrats will recognize that deferring to 
     their Senate colleagues is preferable to reneging on their 
     own word and publishing Trump's returns outside the context 
     of the presidential audit program review that they promised. 
     If, instead, House Democrats release the returns now, Trump 
     and his supporters will charge Democrats with duplicity for 
     saying one thing in litigation and doing another thing 
     afterward--and the charge won't be entirely baseless. That 
     would, perversely, allow Trump to transform the matter of his 
     tax returns from a political vulnerability for him to a 
     potential liability for Democrats. And beyond questions of 
     political strategy, promise-keeping is--of course--an 
     important value in itself.
       So yes, presidents should release their tax returns, but 
     that doesn't release House Democrats from the avowals about 
     their motives that they have made since 2019. In their last 
     weeks in the majority, House Democrats have another 
     opportunity to demonstrate why they deserve the nation's 
     trust. They should seize it--even if that means those of us 
     who have been waiting for years to know what's buried in 
     Trump's tax returns might have to wait a little longer.

  Mr. BRADY. Madam Speaker, I reserve the balance of my time.

                              {time}  1015

  Mr. NEAL. Madam Speaker, I yield 1\1/2\ minutes to the gentleman from 
Nevada (Mr. Horsford), who has been a leader on this issue and gave one 
of the most moving addresses as the caucus ensued.
  Mr. HORSFORD. Madam Speaker, I thank the distinguished chairman, Mr. 
Neal, for yielding time and for leading this important legislation. I 
also thank him for the opportunity to serve on this important 
committee.
  I also thank the ranking member for always showing respect in our 
deliberations. All the best to you in your future deliberations.
  Madam Speaker, I rise today in support of H.R. 9640, the Presidential 
Tax Filings and Audit Transparency Act of 2022.
  As the chair has said, since 1977, the IRS adopted a policy of 
conducting mandatory audits on the President while they are in office 
as a check on their power. Disturbingly, our committee found that the 
IRS had all but given up and ceased this program under the previous 
administration.
  As our colleagues on the other side of the aisle have chipped away at 
the funding for the IRS, their talent pool has shrunk. They have been 
unable to retain the kind of tax and financial experts that are 
actually needed to review the complex tax returns of some of the 
wealthiest.
  Meanwhile, those on the lower income spectrum, especially those with 
children who claim the earned income tax credit, are more likely to be 
audited. In fact, in reports from our committee, five times more likely 
to be audited are those individuals on the low-income spectrum than the 
most wealthy.
  The evidence is clear: Congress must step in. This is why this 
legislation must be passed.
  Madam Speaker, I urge my colleagues to vote ``aye'' on this measure 
and to put the confidence of the American people in our tax system once 
again.
  Mr. BRADY. Madam Speaker, I include in the Record an August 2, 2022, 
blog post from the Committee on Ways and Means titled: ``New Schumer-
Manchin Bill Will Supercharge Long History of IRS Abuses.''

 New Schumer-Manchin Bill Will Supercharge Long History of IRS Abuses, 
                            August 2, 2022.

       Despite a long history of IRS abuses, Democrats have 
     revived their proposal to send 87,000 new IRS agents after 
     you and your family-owned business on the belief that 
     everyone is a tax cheat. The IRS has already been targeting 
     lower and middle income earners, yet Democrats want to hire 
     new IRS agents to audit individuals and small businesses. 
     They've also promised to revive their invasive bank 
     surveillance scheme.


democrats want to increase audits for all individuals by more than 1.2 
                           million per year:

       A Senate Finance Committee analysis shows the $45.6 billion 
     for ``enforcement'' would ``predominantly hit taxpayers who 
     have low (or very low) Adjusted Gross Income. Nothing in the 
     proposal would change that fact.''
       Nearly half of the audits would hit Americans making 
     $75,000 per year or less.
       Low-income taxpayers making up to $25,000 per year would 
     see more audits too.
       Despite a clear need for greater taxpayer customer service 
     amidst a historic tax return backlog, only $3.2 billion of 
     Democrats' $80 billion is earmarked for that purpose.
       Supercharging the IRS will lay the groundwork for the 
     monitoring the Biden Administration has pledged to impose. 
     Top Biden officials have made clear they have not given up on 
     implementing IRS bank surveillance.


 Overly broad IRS targeting spanning decades has claimed many victims, 
                 and Democrats are trying to revive it.

       Former IRS official Lois Lerner apologized in 2013 that Tea 
     Party groups and other groups had been targeted for audits of 
     their applications for tax-exemption, which effectively 
     delayed that status until they could no longer take effective 
     part in the 2012 election. The Treasury Inspector General 
     found that ``Inappropriate Criteria Were Used to Identify 
     Tax-Exempt Applications for Review back in 2013.
       In 1998, the Waslington Post reported that ``An Oklahoma 
     tax-return preparer, a Texas

[[Page H9999]]

     oilman and a Virginia restaurateur told lawmakers how raiding 
     parties of armed agents from the IRS Criminal Investigation 
     Division barged into their homes or offices, frightened their 
     employees and families--and ultimately came up empty-
     handed.''
       ``Two of the men said they later found that former 
     employees had precipitated the raids, and that the IRS had 
     done little or no checking on their informants' credibility.
       The third witness said he never could determine why he was 
     targeted.''
       In 1997, CNN reported testimony from an expert that the IRS 
     was ``the best secret-keeping agency in our government today: 
     ``I discovered that the IRS does keep lists of American 
     citizens for no reason other than that their political 
     activities might have offended someone at the IRS; about how 
     the IRS believes that anyone who offers even legitimate 
     criticism of the tax collector is a tax protester; about how 
     the IRS shreds its paper trail, which means that there is no 
     history, no evidence and, ultimately, no accountability.''
       Robert Schriebman, a tax professor at the University of 
     Southern California and author of eight books critical of IRS 
     practices and procedures, decried the agency's ability to 
     ignore citizens' due-process protections. ``The IRS can take 
     a taxpayer's home by just the signature of the district 
     director alone,'' he said.
       These abuses led to numerous attempts at overhauling the 
     agency, and the latest still has not yet been implemented.


  Irs agents have wrongly seized millions from small businesses when 
                         given the opportunity

       In an apparent show of strength, past IRS actions led to 
     the seizure of more than $43 million from bank accounts of 
     hundreds of small businesses; the results of those actions in 
     a recent case led to local wedding dress shop being 
     permanently shut down.
       Only after intense pressure from Congress did the IRS 
     return the money that had been taken to some of the 
     businesses, including a Maryland dairy farmer.


IRS political leaks have been a problem whenever Democrats have been in 
                            the White House

       The last time President Biden was in the White House in 
     2011, Democrats pushed for billions more in enforcement 
     without providing clear, independent analysis supporting the 
     funding, relying on information provided by activist groups 
     aligned with their political objectives, and the IRS, which 
     stood to gain funding.
       Prior to the 2021 leak, ProPublica previously received (and 
     published) leaked taxpayer information from the IRS in 2012 
     that just so happened to include critics of the Democrat 
     administration.


   Political targeting By IRS threatens religious organizations and 
                             critics alike

       The IRS initially denied a Christian organization tax-
     exempt status because its emphasis on certain ``Bible 
     teachings are typically affiliated with the [Republican] 
     Party and candidates.''
       This is particularly concerning given the agency's prior 
     history of targeting tax exempt groups for additional 
     scrutiny based on their perceived political affiliation.
       Recently, Democrats in Congress asked the IRS to increase 
     scrutiny of groups seeking church status.


                  IRS mismanagement is well documented

       An audit of the IRS itself, conducted from FYs 2010-2012 
     and published in 2013 found ``inappropriate use of taxpayer 
     funds being spent on conferences and reviews selected 
     conferences to determine whether the conferences were 
     properly approved, and the expenditures were appropriated.''
       Another audit in 2019 found that the IRS wasted millions of 
     dollars on software licenses it purchased but never used due 
     to mismanagement of IT contracts and systems updates.
       Despite the Biden Administration's claim that more money 
     will increase IRS audits and increase revenue from wealthy 
     individuals and corporations, the Inspector General actually 
     found that after spending $22 million and 200 hours auditing 
     large businesses, the IRS was unsuccessful in bringing in 
     money to the Treasury from those audits nearly 50 percent of 
     the time.
  Mr. BRADY. Madam Speaker, I reserve the balance of my time.
  Mr. NEAL. Madam Speaker, I yield 1 minute to the gentleman from Texas 
(Mr. Green), who has energetically spoken about this issue in the past 
and will, I am sure, in the future.
  Mr. GREEN of Texas. Madam Speaker, and still I rise. I rise today 
because I believe we have a duty, a responsibility, and an obligation 
to protect the great and noble American ideals that are the foundation 
of this country.
  We have a duty to protect what John Adams, the second President, 
brought to our attention, that we are a country of laws, not men, and 
what Teddy Roosevelt, the 26th President, brought to our attention, 
that no one is above the law.
  The President has awesome authority. The IRS is under the auspices of 
the executive branch. We must put in place laws to assure us that there 
are no conflicts of interest being perpetrated by a President who has 
control of the agency that is supposed to audit his taxes.
  We have a duty, a responsibility, and an obligation. I thank Mr. Neal 
for living up to the duty, the responsibility, and the obligation.
  I respect my friend on the other side from Texas. We disagree. I wish 
him the best. But we have to go on, and the country needs this 
legislation. I encourage my colleagues to support it.
  Mr. BRADY. Madam Speaker, I include in the Record a 2017 House report 
where the chairman said: ``Committee Democrats remain steadfast in our 
pursuit to have [President Trump's] individual tax returns disclosed to 
the public,'' which can be found at: https://www.congress.gov/
congressional-report/115th-congress/house-report/73/1
  Mr. BRADY. Madam Speaker, I reserve the balance of my time.
  Mr. NEAL. Madam Speaker, I yield 1 minute to the gentlewoman from 
Texas (Ms. Jackson Lee), who has been outspoken on this issue, as well.
  Ms. JACKSON LEE. Madam Speaker, it is good in this season to be 
surrounded by truth.
  Let me rise to support H.R. 9640, the Presidential Tax Filings and 
Audit Transparency Act of 2022, because this is a necessity.
  When the Committee on Ways and Means investigated the IRS' execution 
of its mandate to audit the taxes of a sitting President, they found 
that, during the Trump administration, the IRS has been in serious 
dereliction of its duty to audit the taxes of Donald Trump when he had 
been President. In fact, we have found and believe that at one time he 
paid zero.
  I don't want to necessarily focus on Donald Trump, but he happens to 
be at the core issue of the fact of: Are we an equal society? The 
Committee on Ways and Means has emphasized that we are.
  It leads us to the obvious questions of: Why? Did the IRS simply 
forget to do it? Did someone misplace his tax returns? Did the auditor 
of Presidential tax returns retire?
  I think this legislation is imperative because it must be a general 
perspective that transparency is for everyone.
  Let me be very clear: There are hardworking members of the IRS, 
hardworking members of that team.
  The SPEAKER pro tempore. The time of the gentlewoman has expired.
  Mr. NEAL. Madam Speaker, I yield an additional 30 seconds to the 
gentlewoman from Texas.
  Ms. JACKSON LEE. Madam Speaker, we know and see them all the time.
  Madam Speaker, in addition to the dereliction regarding the audit of 
Donald Trump, we have heard that if you are a schoolteacher, you are 
audited.
  I want to say to the IRS Commissioner: You are derelict in your 
duties. You are derelict in your sensitivity to constituents, to calls 
from Members, and you are derelict in your duty as to what you are 
supposed to do as related to the President of the United States, not 
only because he was President but because he was an individual who 
continued to ignore the laws of the land.
  I said today was a day of truth in this holiday season. This 
legislation will bring truth and respect. Let's see those tax returns, 
and let the IRS do its job on behalf of the American people.
  Madam Speaker, I rise in strong support of H.R. 9640, the 
Presidential Tax Filings and Audit Transparency Act of 2022.
  This legislation arose by necessity. When the Ways and Means 
Committee investigated the IRS's execution of its mandate to audit the 
taxes of a sitting president, it found that, during the Trump 
administration, the IRS had been in serious dereliction of its duty to 
audit the taxes of Donald Trump when he had been president.
  This was especially troubling because, based on publicly known and 
commonly held information, Donald Trump's activities and investments 
presented a wide range of questionable and potentially problematic tax 
issues, to a far greater degree than any previous president.
  Donald Trump's taxes are the prototypical example of why the policy 
was established in the 1970s that required the IRS to audit the taxes 
of a sitting president.
  And yet, as the Ways and Means Committee found, it did not happen, 
either never being initiated or never being completed.
  It leads us to the obvious question: Why?
  Did the IRS simply forget to do it?
  Did someone misplace his tax returns?
  Did the auditor of presidential tax returns retire?
  While we don't know the exact answer, the IRS's failure to conduct 
its statutorily mandated audit of the president's taxes raises the 
possibility of a nefarious reason for the failure.

[[Page H10000]]

  Given the well-documented, extensive, and repeated malfeasance that 
was endemic to the presidency of Donald Trump--including all of the 
evidence presented during his two impeachment trials and his attempt to 
obstruct the effectuation of the 2020 election and subvert the 
Constitution, as exposed by the January 6th Select Committee--it is 
obvious that Trump had little or no interest in personally adhering to 
the law.
  Because of that, Congress would be naive to believe that the IRS's 
failure to audit Trump's taxes was merely an administerial error.
  Whether the failure was due to a specific instruction that was 
transmitted directly to the IRS leadership, or an implied directive 
that was recognized, or possibly some other means of observing or 
conveying Trump's wishes, it would be foolish to ignore the possibility 
that a president who flouted the law with impunity on so many occasions 
had instead, in total contrast, insisted on strict adherence to the law 
in connection to the audit of his personal taxes, and that his views 
played no part in the failure of the IRS to audit his taxes.
  This obvious observation is accentuated by Trump's public statements 
displaying his antipathy to paying his fair share of federal taxes. 
Perhaps most resoundingly, during a 2016 debate, he said that, by 
paying nothing in federal taxes over a series of years, ``That makes me 
smart.''
  All of this pertinent background underscores the obvious basis for 
the legislation that we are now considering: Congress must ensure that 
the failure by the IRS to audit a sitting president's taxes Never 
Happens Again.
  This bill codifies the requirement that the IRS conduct and complete 
an audit of the sitting president's taxes each year, and publicly 
disclose certain information about its findings.
  The bill also requires the IRS to audit any additional filing by a 
former president that relates to a year in which he or she had been in 
office.
  Since it is the responsibility of Congress to ensure that the tax 
code is administered fairly for every American, it is especially 
important that Congress apply that to the most powerful American at any 
given time: the president of the United States.
  Fairness requires even-handed application of the law to everyone, 
including those with the most influence over our governmental 
institutions.
  Failure to adhere to this precept would subordinate public confidence 
in our democracy the whims of the person who presides over the entire 
executive branch of our government.
  Failure to abide by fairness in the enforcement of our tax code would 
negate fairness as a fundamental American principle.
  Failure to apply the tax code to the president in an even-handed 
manner, just like it applies to other Americans, would assert 
acquiescence of justice and the rule of law to Machiavellian, 
autocratic, narcissistic personal interests and personal power.
  That may be how things work in countries run by monarchs, but that's 
not how the United States works.
  In fact, it is antithetical every stroke of the quill that composed 
our Constitution.
  Madam Speaker, I strongly support this legislation because it is 
necessary and appropriate, and it effectuates bedrock American 
principles.
  I urge all my colleagues to vote YES on this bill to empower the IRS 
to do its job--free of fear or favor--and remind every future president 
that he or she is subordinate to the Constitution and the rule of law, 
just like every other person in our country.
  The SPEAKER pro tempore. Members are reminded to address their 
remarks to the Chair and not to a perceived viewing audience.
  Mr. BRADY. Madam Speaker, I yield myself such time as I may consume.
  Madam Speaker, I would note that, every year, President Trump's tax 
returns were under audit and that the tradition of making Presidential 
tax returns public is just that, a tradition, not a law, and unrelated 
to the Presidential audit program.
  I would also note that while I have loved serving with my colleagues 
from Houston, I would note that they were among the very first Members 
of Congress to introduce impeachment resolutions against this President 
in the very first year of his Presidency, revealing that this is 
political targeting and nothing else.
  Madam Speaker, I reserve the balance of my time.
  Mr. NEAL. Madam Speaker, I yield myself such time as I may consume.
  Before I finish my time here, I do thank Kevin Brady. We had an 
excellent relationship at the committee. I can speak for all the 
Democrats on the committee that they had high regard for Kevin Brady 
when he was in the majority and when he was in the minority for the way 
he allowed the minority, us at the time, to use the time that was 
allocated to us. I never thought during that time that Mr. Brady did 
anything that was mean or malicious.
  In addition, I think what is important to point out here, as he did 
in his comments, is that we did big things during that time. When you 
stop and consider the CARES Act, when you consider what we did in the 
health space, retirement and savings, what we were able to do with 
USMCA, all of that was done in a bipartisan manner. I think part of it 
is a reflection of his personality, which fundamentally lacks malice.
  Madam Speaker, I reserve the balance of my time.
  Mr. BRADY. Madam Speaker, I yield myself the balance of my time.
  Madam Speaker, I include in the Record an October 2018 article, 4 
years ago, from the San Francisco Chronicle, where the Honorable Nancy 
Pelosi said to expect Democrats to immediately try to force President 
Trump to release his tax returns if they take back the House in 
November, exposing the true purpose of this effort.

             [From the Bloomberg Government, Oct. 11, 2018]

 SF Chronicle: Pelosi: Trump's Tax Returns are Fair Game if Democrats 
                               Win House

                          (By John Wildermuth)

       Expect Democrats to immediately try to force President 
     Trump to release his tax returns if they take back the House 
     in November, Minority Leader Nancy Pelosi said Wednesday.
       Demanding the president's tax returns ``is one of the first 
     things we'd do--that's the easiest thing in the world. That's 
     nothing,'' Pelosi told The Chronicle's editorial board in an 
     hour-long interview.
       Although a 1924 provision of the Internal Revenue Code 
     gives certain congressional committees the right to request--
     and release--the tax records of even the president, it's 
     unlikely Trump would surrender those documents without an 
     all-out legal battle. He has refused to release his returns 
     since he announced he was running for president, arguing 
     first that he was being audited and later that voters don't 
     care.
       The GOP-led Congress has joined in keeping those records 
     private, regularly voting down Democratic efforts to make 
     Trump turn them over.
       Forcing Trump to release his returns would not necessarily 
     make them public, but would allow a Democratic-run 
     congressional committee to decide whether there is 
     information in those returns that needs to be investigated.
       Whether that happens hinges on Democrats winning the House 
     or the Senate. With the Nov. 6 election less than four weeks 
     away, Pelosi sounded confident about both the House 
     Democrats' chances and her own political future.
       ``I believe we would win if the election was today,'' she 
     said. And although more than 50 Democratic candidates have 
     said they wouldn't vote for Pelosi to lead the House, the San 
     Francisco Democrat said, ``I believe I will be speaker if we 
     win.''
       Releasing the president's tax returns to a congressional 
     committee would not be revenge for the way Trump and GOP 
     leaders have treated the Democratic minority for the past two 
     years, but a simple matter of oversight by Congress, ``a co-
     equal body of government,'' Pelosi said.
       ``We have to have the truth,'' she said.
       Payback isn't going to be part of a Democratic-led House, 
     Pelosi promised, pushing back against what she called the 
     ``pound of flesh crowd'' of Democrats eager to repay 
     Republicans for every political slight and attack since Trump 
     was elected.
       ``We will seek bipartisanship where we can,'' Pelosi said. 
     ``One of the reasons we should win is that we're not like 
     them, and we're not going to be like them.''
       The Democratic leader also says she doesn't have much 
     choice. No matter what happens on election day, Trump is 
     still going to be president and she will have to work with 
     him.
       ``We need to get a signature, which requires some 
     bipartisanship, some common ground,'' Pelosi said, which she 
     admitted wasn't always easy.
       ``I, probably more than most people do, respect the office 
     he serves in, probably more than he does,'' she said. ``But 
     he is the president--we have to find our common ground. . . . 
     We want to get results for the American people.''
       But that's going to mean discussions and compromise, not 
     surrender, Pelosi said. Democrats ``will never negotiate away 
     our values,'' she said.
       Pelosi is confident there are areas where Democrats can 
     reach agreement with Trump and Republicans, as they did when 
     Republican George W. Bush was president.
       Despite disputes over the Iraq War and other issues, ``we 
     worked together, we disagree and we agreed, and that's the 
     marketplace of ideas that we live in,'' she said.
       Areas where there could be common ground include national 
     infrastructure improvements, a plan for Dreamers, 
     undocumented residents who arrived in this country

[[Page H10001]]

     as minors, and ways to curb gun violence, Pelosi said.
       There's also public support for efforts to allow the 
     Department of Health and Human Services to negotiate for 
     lower drug prices, she added.
       Pelosi also weighed in on some local issues, saying she 
     supported San Francisco's efforts to establish a safe 
     injection site for drug users, something Gov. Jerry Brown 
     vetoed last month. She also backed changes in federal 
     marijuana laws, although she admitted, ``I don't see this 
     president signing any such thing.''
       But those concerns are far from the top of the Democrats' 
     ``to-do'' list if they take back the House. ``The first order 
     of business is the economic security of America's working 
     families--that is what people care about,'' Pelosi said.
       For Pelosi, that concern connects directly with San 
     Francisco's Proposition C, which would tax large companies to 
     raise an estimated $300 million a year for homeless programs.
       Pelosi said she supports the measure because it's something 
     the city needs to do. She acknowledged the opposition from 
     her political ally Mayor London Breed, who has said that 
     before the city pours millions of dollars more into homeless 
     programs, ``San Franciscans deserve accountability for the 
     money they are already paying.''
       ``I don't disagree with the mayor that there should be 
     accountability and there should be a plan'' about how to use 
     the funds, Pelosi said. ``I have great confidence in the 
     mayor that she can handle it if Prop. C wins.''
       Efforts to deal with social problems like homelessness, 
     hunger and housing insecurity require a new vision from 
     Congress, she said.
       ``We have to think in a different way about it, and when we 
     think big, we have to put our hands in the pockets where the 
     money is,'' Pelosi said.
       Homelessness ``is not an issue, it's a value. It's an ethic 
     that we have not properly addressed.''
  Mr. BRADY. Madam Speaker, I yield myself the balance of my time.
  Madam Speaker, Nancy Pelosi is not alone. Democrat after Democrat on 
this committee and in this Congress made it clear years ago that they 
were targeting President Trump to try to force his tax returns to be 
made public, even though the law doesn't require it at all and, as was 
revealed in our committee hearing, it has nothing to do with the 
Presidential audits.
  In fact, in our markup, again and again, we heard from Members who 
said we must force these private tax returns to be made public so we 
can see his dealings, so we can see his taxes, so we can criticize. 
Nothing to do with the Presidential audit process.
  That is our concern today, that under the new standard that has been 
set, and the Supreme Court has affirmed, two individuals in Congress, 
the chairman of the Committee on Ways and Means and the chairman of 
Senate Finance Committee, will have nearly unlimited power, with almost 
any excuse, to obtain, to investigate, and to make public those very 
private tax returns.
  We are not alone in our concerns. Other scholars have made the point 
that we have a voluntary tax system and that if Americans don't believe 
and can't trust that their tax returns won't be kept private, if they 
have to worry that if they end up on the enemy's list in Congress, that 
they, too, can be a target. Under this new process and this new 
standard, the privacy protections of the last half a century are gone.
  My worry, and I think the worry of every Republican here, and I hope 
some of our Democrat friends, as well, is that this will provide a 
dangerous new political weapon that invites political retribution where 
that cycle will continue and our politics will be worse, harsher, 
uglier, and more divisive because of this action.
  Again, at the end of the day, whether a President makes their tax 
returns public or not, today it is not the law. While I would recommend 
it for all, the truth of the matter is, at the end of the day, this is 
political targeting. It can be applied not just to the President but to 
every American.
  I am worried that it is not just public officials at risk. It is 
private citizens. It could be supporters. It could be business or labor 
leaders. It could be the Supreme Court that someone seeks to 
delegitimize. That is our concern here.
  This is why we are fighting this fight as Republicans, to protect the 
privacy of every American, to make sure they are not targeted by 
partisans in Congress.
  I will tell you, I am very worried that every chairman of those two 
committees will face incredible pressure to target Americans, political 
enemies, and opponents, and I don't think we should ever go down that 
road. Regrettably, we are, and that is why we are here.
  I have respected Chairman Neal for many years and treasure our 
working relationship and the accomplishments we have done. I will miss 
you, friend.
  Before we conclude today, I want to say a special thank-you to 
several members of the Committee on Ways and Means Republican staff who 
have worked so hard on this issue for years: Sean Clerget, Derek 
Theurer, Caroline Jones, Molly Fromm, Brittany Havens, Paige Decker, 
J.P. Freire, and, of course, the remarkable staff director of the 
Committee on Ways and Means Republicans, Gary Andres. He has done a 
great job for this committee and this country.
  Madam Speaker, I yield back the balance of my time.
  Mr. NEAL. Madam Speaker, I yield myself the balance of my time for 
closing.
  The constant theme that we have heard today from our Republican 
colleagues is that this is about targeting an individual. This is a 
chance to clarify the law that they suggest is currently in a 
convoluted stage, which means that there is, in their judgment, 
sufficient confusion about the law as to whether or not the process 
should play out.
  What this legislation argues, I think, with great proficiency is the 
following, and that is that we should codify the system that we have 
discovered in recent days is not only dysfunctional but is nonexistent.
  Nine out of the last 10 Presidents of the United States have 
voluntarily released their tax forms. It dates to Richard Nixon in a 
letter to the then-chairman of this committee, Wilbur Mills.
  Barack Obama and Joe Biden have both indicated they have been fully 
audited. What we are suggesting today is that this is an opportunity to 
clear up the question of how the mandatory audit that is highlighted in 
regulations at the IRS plays out.
  By the way, when we say it is not in law, this institution here 
functions on the basis of rules as well as law. The rules in the IRS 
manual said that the audit ought to take place. We have discovered that 
not only did the audit not take place but it hasn't even been 
completed.
  A reminder: This is not about a President. This is about the 
Presidency going forward.

                              {time}  1030

  This was not done with malicious intent. It was not done in a 
clandestine manner. It was this chance to say, okay, if there is a 
legitimate argument about how the mandatory audit system plays out, 
let's straighten it out this morning. Easily done and accomplished. 
Paying taxes is a core responsibility, a reflection of our faith in 
common citizenship.
  Despite the idea that we talk about a voluntary system, treasure the 
idea that about 87 percent of the American people pay their taxes on 
time. That really speaks, I think, to the intent and sincerity that 
they feel about a functioning government. All of us are expected to 
fulfill that responsibility.
  In exchange for voluntary compliance, we have to be assured that a 
fair and well-functioning system ensures that everyone else is 
cooperating, too. This shouldn't be the kind of country that allows 
those with power and privilege to be held above the law that applies to 
everyone else. That is not part of our national character. That is not 
our ethic as a people.
  Here, no one, no matter how powerful, should be out of the reach of 
the tax system, least of all not in compliance with our tax laws.
  The IRS failed its own policy to audit a President in an affront to 
our shared sense of justice and fairness. Everybody on this occasion 
acknowledges that, the audit did not take place. And no audit has been 
completed 3 years later.
  The legislation before us, H.R. 9640, rectifies the situation. It 
offers great clarity.
  Madam Speaker, I urge all of my colleagues to support this 
legislation, and I yield back the balance of my time.
  Mr. PASCRELL. Madam Speaker, I was the first member who advocated for 
reviewing and releasing Donald Trump's tax returns. I've been on this 
quest for nearly 6 years.
  I applaud Chairman Neal for fighting until the very end. This was not 
about 1 man. The law was always on our side.

[[Page H10002]]

  Our committee investigation makes crystal clear why Trump and his 
cronies obstructed our work. Trump's handpicked Treasury Secretary and 
IRS head were at best derelict. At worst they were corrupt and 
criminal.
  Trump paid a pittance in taxes for years. He overinflated losses to 
shirk his duty as an American citizen.
  Trump's government failed to conduct a mandatory review of his tax 
records. They broke the law.
  We provided the IRS with funds to prevent tax cheats from abusing our 
tax code. Now, we must ensure the IRS cannot meddle with the audit 
process and presidential returns are made public.
  Americans must have faith that our tax system is fair. No one is 
above the law. It is time to act.
  The SPEAKER pro tempore. Pursuant to House Resolution 1529, the 
previous question is ordered on the bill.
  The question is on the engrossment and third reading of the bill.
  The bill was ordered to be engrossed and read a third time, and was 
read the third time.
  The SPEAKER pro tempore. The question is on passage of the bill.
  The question was taken; and the Speaker pro tempore announced that 
the ayes appeared to have it.
  Mr. BRADY. Madam Speaker, on that I demand the yeas and nays.
  The yeas and nays were ordered.
  The SPEAKER pro tempore. Pursuant to clause 8 of rule XX, further 
proceedings on this question will be postponed.

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